Green Claims Directive: What It Means for Irish Businesses

The EU Green Claims Directive is about to change how every business in Europe talks about its environmental performance. If your company uses terms like “eco-friendly”, “carbon neutral”, or “sustainable” in its marketing, packaging, or sales materials, you will need hard evidence to back those claims up — or stop making them. For Irish businesses, this is not a distant regulatory prospect. It is arriving alongside a wave of EU sustainability legislation that is already reshaping how companies operate and communicate.

What the Green Claims Directive Is

The Green Claims Directive (formally the Directive on substantiation and communication of explicit environmental claims) is a proposed EU regulation designed to tackle greenwashing by setting clear rules for how businesses make environmental claims to consumers.

It works alongside the Empowering Consumers Directive (Directive 2024/825), which was adopted in early 2024 and amends the Unfair Commercial Practices Directive. The Empowering Consumers Directive already bans generic environmental claims that cannot be substantiated — terms like “environmentally friendly”, “green”, or “eco” used without qualification. The Green Claims Directive goes further by establishing a detailed framework for how substantiation must work: what evidence is required, who verifies it, and how claims must be communicated.

Together, these two directives create a comprehensive legal framework that will fundamentally change environmental marketing across the EU. The Empowering Consumers Directive sets the floor (no unsubstantiated claims). The Green Claims Directive builds the compliance architecture (how to substantiate the claims you do make).

What Counts as a Green Claim

The Directive covers explicit environmental claims — any voluntary statement, label, or marketing message that suggests a product, service, or company has a positive environmental impact, is less damaging than alternatives, or has improved its environmental performance over time.

This includes claims about:

• Climate and carbon — “carbon neutral”, “net zero”, “climate positive”, “reduced carbon footprint”
• Resource use — “recyclable”, “made from recycled materials”, “circular”, “zero waste”
• Biodiversity and nature — “biodiversity positive”, “ocean friendly”, “sustainably sourced”
• Pollution — “non-toxic”, “chemical free”, “clean”
• General environmental impact — “eco-friendly”, “green”, “sustainable”, “environmentally conscious”

The Directive also covers environmental labels — any voluntary trust mark, quality mark, or label that suggests environmental credentials. This captures the hundreds of private sustainability labels and certification schemes currently in use across the EU.

Claims required by existing EU or national law (such as CSRD disclosures or mandatory energy labels) are excluded — the Directive applies only to voluntary claims.

Why Substantiation Is More Complex Than It Appears

The substantiation requirements under the Directive are detailed, technically demanding, and far more involved than most businesses expect. What looks straightforward in a regulatory summary becomes a multi-layered compliance challenge in practice — one that sits at the intersection of environmental science, legal interpretation, and verification standards. This is where companies that try to manage the process internally most often come unstuck.

Full Lifecycle Scientific Evidence

Claims must be based on widely recognised scientific evidence, using accurate information and taking into account relevant international standards. Critically, the assessment must consider the full lifecycle of the product or service — raw material extraction, manufacturing, distribution, use, and end-of-life. A claim cannot cherry-pick a single favourable metric while ignoring negative impacts elsewhere in the value chain.

For example, claiming a product is “sustainable” because it uses recycled packaging is insufficient if the production process generates significant emissions or water pollution. Understanding where your genuine environmental impacts lie — and where the risks in your claims are hidden — requires deep expertise in lifecycle thinking and environmental measurement. If you are unsure where your claims stand, talk to our team about a claims risk assessment before enforcement begins.

Recognised Methodologies with Strict Requirements

Substantiation must follow established methodologies, including lifecycle assessment (LCA) approaches consistent with the EU’s Product Environmental Footprint (PEF) and Organisation Environmental Footprint (OEF) methods. These are not simple frameworks — PEF alone involves 16 impact categories, complex allocation rules, and strict data quality requirements. Selecting the wrong methodology or applying it incorrectly can invalidate an entire claim and the investment behind it. This is specialist territory, and a misapplied methodology is one of the most common — and most expensive — errors we see.

The Carbon Offset Minefield

A critical provision for Irish businesses making carbon neutral or net zero claims: the Directive requires companies to clearly separate their own emission reduction performance from any carbon credits or offsets purchased. Claims cannot present offsetting as equivalent to actual emission reductions. This is not a simple disclosure exercise — it requires robust carbon accounting that can withstand independent scrutiny, plus a credible reduction trajectory and additional categorisation, governance, and verification requirements that demand specialist expertise to get right.

Mandatory Third-Party Verification

All claims must be verified by an accredited independent verifier before they can be used. This is not a rubber-stamp exercise. Verifiers will assess the methodology, data quality, scope boundaries, and conclusions of each claim. Preparing for verification — assembling the evidence, ensuring data integrity, addressing gaps, and presenting the substantiation in the format verifiers expect — is a significant undertaking in its own right. Our ESG advisory team works with Irish businesses to build verification-ready evidence bases, so reach out if you need support navigating this process.

Pre-Approval for New Labels

New environmental labelling schemes will require approval at EU level. This is intended to halt the proliferation of private green labels — many of which have weak criteria, no independent verification, and create confusion rather than clarity for consumers. Existing EU-level schemes (such as the EU Ecolabel) will continue, but new national or private schemes will face far higher barriers to entry.

Timeline and Status

The European Commission published its proposal for the Green Claims Directive in March 2023. The European Parliament adopted its position in March 2024, and Council negotiations were ongoing through early 2025.

However, on June 20, 2025, the European Commission announced its intention to withdraw the Green Claims Directive proposal, following pressure from the European People’s Party (EPP). The scheduled trilogue negotiations between the Commission, Council, and Parliament were cancelled. The primary criticism centred on the planned inclusion of micro-enterprises and the anticipated regulatory burden. As of March 2026, the legislative process remains suspended and the Directive’s future is uncertain.

The key timeline milestones:

• March 2023: Commission proposal published
• Early 2024: Empowering Consumers Directive adopted (Directive 2024/825) — Member States must transpose by March 2026, with provisions applying from September 2026
• March 2024: European Parliament adopted its position
• June 2025: Commission announced intention to withdraw the proposal; trilogue cancelled
• Current status: Legislative process suspended — no timeline for adoption

Despite the Green Claims Directive being on hold, the Empowering Consumers for the Green Transition Directive (Directive 2024/825) remains in force. Member States must transpose it by March 2026, with provisions applying from September 2026. This Directive bans generic unsubstantiated environmental claims such as “eco-friendly” or “green” and prohibits product-level climate-neutral claims based solely on offsets — meaning Irish businesses making vague environmental claims are exposed regardless of the Green Claims Directive’s fate.

How It Affects Irish Businesses

The impact will be felt across every sector where businesses make environmental claims to customers, whether B2C or B2B.

Marketing and Communications

Every environmental claim on your website, in your brochures, in your advertising, and on social media will need to be substantiated with evidence and verified by a third party. “We’re committed to sustainability” is not a claim that can be substantiated under this framework — either make a specific, evidence-backed claim or remove the statement.

Product Labelling and Packaging

If your product packaging carries environmental claims — “recyclable”, “compostable”, “made from sustainable sources” — you will need lifecycle-based evidence and third-party verification for each claim. Private sustainability labels without EU-level approval will not be permitted on new products.

Carbon Neutral Claims

This is where the most immediate disruption will occur. Many Irish businesses have made carbon neutral claims based on purchasing carbon offsets without undertaking significant emission reductions. Under the Directive, these claims will need to clearly separate the company’s own emission reduction performance from its offset purchases. Claims that present offsetting alone as carbon neutrality will not comply. If your climate claims rely on offsets, get in touch to understand what needs to change before the September 2026 deadline.

Supply Chain and B2B Claims

The Directive applies to all voluntary environmental claims, including those made in B2B contexts. If you tell your business customers that your products or services have specific environmental attributes, those claims must meet the same substantiation and verification standards.

Claims That Will Need to Change

Based on the Empowering Consumers Directive provisions applying from September 2026, the following common claims will need to be substantiated, modified, or withdrawn:

Vague, generic claims — “Eco-friendly”, “green”, “sustainable”, and “natural” used as general descriptors without specifying what they mean and providing verifiable evidence.

Unsubstantiated carbon claims — “Carbon neutral” based solely on offsets, “climate positive” without lifecycle evidence, and “low carbon” without defined benchmarks. Each of these requires specific substantiation that goes well beyond what most companies currently have in place.

Misleading comparisons — Percentage reduction claims, comparative statements, and “greener than” claims all require defined baselines, recognised methodologies, and verifiable reference points.

Unverified labels — Private sustainability marks, self-awarded badges, and industry schemes without independent third-party accreditation.

Irish businesses that are already operating under ISO 14001 environmental management systems or conducting rigorous carbon accounting will find themselves better positioned — these frameworks provide the structured evidence base the Directive demands.

Why Professional Support Matters

The Green Claims Directive is not a marketing refresh. It is a regulatory compliance exercise that demands scientific rigour, recognised methodologies, and independent verification. The businesses most at risk are those that attempt to navigate this without specialist expertise — because the consequences of getting it wrong are severe and often irreversible.

A poorly scoped lifecycle assessment invalidates a claim entirely. An incomplete carbon footprint — missing material Scope 3 categories, for instance — can unravel an entire carbon neutrality position and expose the company to enforcement action. Even well-intentioned claims can be classified as misleading if the underlying methodology does not meet the technical standards regulators and verifiers expect. These are not theoretical risks: the Empowering Consumers Directive provisions apply from September 2026, and Irish businesses face fines, product restrictions, exclusion from public procurement, and reputational damage.

If you are making environmental claims today, contact us to understand your exposure before enforcement begins.

How Clearscope Helps

We have deep expertise in the environmental measurement frameworks, verification standards, and regulatory requirements that underpin the Green Claims Directive. Through our ESG advisory and carbon accounting services, we guide Irish businesses through the full claims compliance process — from initial risk assessment through to verification-ready evidence:

• Claims risk assessment — comprehensive review of all environmental claims across your marketing, labelling, and communications, identifying claims at risk of non-compliance and prioritising remediation
• Carbon footprint measurement — rigorous Scope 1, 2, and 3 quantification using GHG Protocol methodology, providing the verified evidence base for climate-related claims
• Lifecycle assessment guidance — ensuring product and service environmental impact assessments use recognised methodologies and meet PEF/OEF requirements
• Offset strategy and disclosure — restructuring how your climate claims present the relationship between genuine emission reductions and offset purchases to meet regulatory requirements
• Verification preparation — assembling your evidence base, addressing data gaps, and preparing documentation for third-party verifier engagement
• Ongoing claims governance — embedding substantiation processes into your marketing and communications workflows so every new claim is compliant before it goes live

The businesses that will benefit most from the Green Claims Directive are those making genuine environmental improvements. We help you build the evidence and systems to prove it — and protect you from the regulatory risks of getting it wrong.

Contact us to discuss your green claims readiness.

Frequently Asked Questions

When does the Green Claims Directive take effect?

The Directive's legislative process was suspended in June 2025 and its future is uncertain. However, the Empowering Consumers Directive provisions banning generic unsubstantiated claims apply from September 2026 — so businesses are exposed regardless.

Does the Green Claims Directive apply to B2B claims?

Yes. The Directive applies to all voluntary environmental claims, including those made to business customers in tenders, sales materials, or marketing.

Can I still claim my product is carbon neutral?

Potentially, but with significant conditions. You must clearly separate emission reductions from offsets and demonstrate genuine operational change. The substantiation requirements are technically demanding and require independent verification.

What evidence do I need to substantiate a green claim?

Claims must be based on recognised scientific methodologies covering the full lifecycle, verified by an accredited independent third party. The specific evidence required depends on the claim type, and the technical bar is higher than most businesses expect.

What happens if I make an unsubstantiated environmental claim?

From September 2026, the Empowering Consumers Directive provisions ban generic unsubstantiated claims and offset-based climate-neutral claims, with enforcement under existing unfair commercial practices law. Penalties include fines, product restrictions, and exclusion from public procurement.